Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
SSINS NO: 6835
IN 84-44
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
June 8, 1984
Information Notice No. NO 84-44: ENVIRONMENTAL QUALIFICATION TESTING OF
ROCKBESTOS CABLES
Addressees:
All holders of a nuclear power reactor operating license (OL) or
construction permit (CP).
Purpose:
This information notice is provided to inform licensees and construction
permit holders of potential generic problems regarding Rockbestos
environmental qualification (EQ) testing of Class 1E electrical cables.
Addressees are expected to review the information for applicability to their
facilities. No specific action or response is required.
Description of Circumstances:
The NRC has performed a number of inspections of the QA programs established
at several environmental testing facilities. This effort was started in late
August 1982 to assess the facilities' establishment and implementation of a
QA program based on the requirements of 10 CFR Part 50, Appendix B. Several
such inspections were recently conducted at the Rockbestos Company in New
Haven, Connecticut. The NRC inspection team reviewed qualification related
documents such as EQ reports, associated supporting items including test
plans, test procedures, test instruments, test log books, related raw data
and QA documents. The inspections revealed several QA nonconformances and
related testing/documentation problems. Details of these nonconformances and
inspection findings are documented in the following NRC Inspection Reports:
99900277/83-01, 99900277/83-02, and 99900277/83-04. Listed below are some of
the QA nonconformances and related testing/documentation problems which may
affect the qualification of Rockbestos cables that are installed at
licensees' facilities:
1. The Rockbestos Company did not impose quality assurance/test control
requirements on an outside test organization which performed testing
(LOCA/ HELB) during the period of 1969-1979.
2. The Rockbestos Company did not establish and implement a QA program in
accordance with 10 CFR Part 50, Appendix B requirements to control
Rockbestos EQ testing; i.e., the EQ program was controlled by a
Rockbestos engineering organization which was not under a QA program
until 1983.
.
IN 84-44
June 8, 1984
Page 2 of 3
3. As a result of inadequate QA controls, testing and the required
documentation were not properly controlled. Several discrepancies
between final qualification reports and supporting test data were
found.
4. Rockbestos' QA and engineering organizations did not impose QA and
technical requirements/acceptance criteria on organizations that
performed qualification testing for Rockbestos between 1969 and 1979.
Furthermore, no supporting test data for these tests were available for
audit at Rockbestos or subtier test organizations.
5. Test equipment and instrumentation were observed to have inadequate
resolution to record LOCA test parameters and functioning of test
specimen during testing.
6. Test equipment was not properly calibrated or under the control of the
calibration system. An internal Rockbestos audit dated May 10, 1983,
documented these generic deficiencies in their calibration system.
7. Test plans, acceptance criteria, and test procedures for certain
qualification tests were not made available during the NRC audits.
8. A number of test deficiencies, deviations, and other anomalies were not
documented and evaluated in the test reports.
Discussion:
The results of the NRC inspections show that several deficiencies were
present in the Rockbestos Company qualification programs in effect at time
of the audit. Individually, some deficiencies could be adequately
reconciled, but taken collectively, the nature and number of deficiencies
identified would not adequately demonstrate that acceptable qualification
had been established. It appears that the validity of some of the Rockbestos
qualification reports is in doubt, however, the NRC staff has concluded at
this time that no immediate safety problem exists in the use of Rockbestos
cables. The NRC staff considers that it is the responsibility of the user
utilities to review the information provided above and take applicable
corrective action to ensure the qualification of Rockbestos cables installed
in their plants. The following possible courses of corrective action should
be considered:
a) Perform a valid qualification test of the installed Rockbestos
cables.
b) Obtain documentation from other available qualification tests
already performed and determine its applicability to the installed
cables.
.
IN 84-44
June 8, 1984
Page 3 of 3
c) Perform analyses of existing qualification reports applicable to
the installed cables to ensure that the documentation relied upon
to demonstrate environmental qualification supports such a
conclusion.
The NRC staff considers this review to be part of the on-going activities
that the licensees are currently undertaking to resolve other environmental
qualification deficiencies to meet the deadline and requirements set forth
in the EQ final rule, 10 CFR 50.49.
Questions regarding details of, and resolutions to the NRC inspection
findings described above should be directed either to the equipment
manufacturer, or the cognizant design/test agency. If you have questions
regarding this information notice, contact the Regional Administrator of the
appropriate NRC Regional Office, or this office.
Edward L. Jordan Director
Division of Emergency Preparedness
and Engineering Response
Office of Inspection and Enforcement
Technical Contact: R. G. LaGrange, NRR
(301) 492-8208
N. B. Le, IE
(301) 492-9673
Attachment:
List of Recently Issued IE Information Notices
